The US Occupational Safety and Health Administration (OSHA) is seeking input from the public on the approach to use in developing its federal standard for combustible dust. In its Advance Notice of Proposed Rulemaking (ANPR) on Combustible Dust, OSHA identified five National Fire Protection Association (NFPA) combustible dust standards that address the hazards of combustible dust processes. Of the five NFPA dust-specific standards mentioned by OSHA, NFPA 654 provides fundamental safety practices to be followed

One approach, consistent with the National Technology and Transfer Act, P.L. 113, would be to incorporate the relevant NFPA standards by reference. This approach has been advocated for some time in the recommendations of the U.S. Chemical Safety and Hazard Investigation Board (CSB) in its Combustible Dust Hazard Study, 2006-H-1, November 2006 and by Congress in its Worker Protection Against Combustible Dust Explosions and Fires Act of 2009, H.R. 849.

NFPA encourages all interested parties to provide input to OSHA by January 19, 2010. An electronic comment form and instructions are available at www.regulations.gov in Docket No. OSHA-2009-0023, RIN 1218-AC41. Additional information is available from OSHA.

Additional BackgroundOver the past 15 years, a number of industries have experienced serious dust explosions causing loss of life and injuries and significant property damage. Three incidents in 2003 that took 14 lives and injured numerous others provided some national focus on the dangers of combustible dusts. CSB sharpened that focus in 2006 with its Combustible Dust Hazard Study, in which it reported that from 1980 to 2005, combustible dusts caused 281 incidents that killed 119 workers and injured 718. Even with the increased attention generated by the 2003 incidents and the CSB findings, an additional 16 deaths and 84 injuries occurred from 2006 to 2008.

The NFPA combustible dust standards, some which date back to the 1920’s, establish a series of steps intended to characterize the hazard and to apply control measures designed to eliminate or minimize the hazard to both workers and the facility. These steps include: hazard assessment, engineering controls (equipment and process isolation), housekeeping, building design, explosion protection, operating procedures, and worker training.

In addition to managing the development and revision of its combustible dust standards, NFPA has actively promoted their dissemination to ensure increased awareness among the owner/operators and enforcing officials by providing training (on-site and at the NFPA Conference & Expo) and working with the Fire Protection Research Foundation. As noted by the CSB in its study, the NFPA standards already provide a comprehensive basis that can be applied to the hazards of combustible dust in industry; there appears to be a lack of awareness of both the problem and this readily available solution. NFPA will continue to work to disseminate information related to its standards and promote their use through training opportunities.

NFPA 654 is currently undergoing revision in preparation for the adoption of the 2011 edition of the standard (to be issued by the Standards Council in mid-2010). For information on the proposed changes to the standard, the Report on Proposals (ROP) is available online. The Report on Comments (ROC) will be completed in early 2010 and added to the Web page at that time.

Additional information on combustible dust explosions can be found in an OSHA Hazard Alert released in March 2008.